Aktualisierte Sanktionsmeldung: Syrien
Executive Summary
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) has amended **Annex 7 of the Ordinance of 8 June 2012 on Measures against Syria (SR 946.231.172.7)**, updating the list of sanctioned persons, entities, and organisations. The associated changes have been implemented in SECO’s SESAM sanctions database and become **legally binding for Swiss financial intermediaries as of 16 June 2026 at 23:00**, triggering immediate screening, asset-freeze, and reporting obligations under Swiss sanctions and AML law.
What Changed
- - The WBF has amended Annex 7 of the Ordinance of 8 June 2012 on Measures against Syria (SR 946.231.172.7), changing the list of sanctioned persons, companies, and organisations connected to Syria.
- The Swiss sanctions database SESAM (SECO Sanctions Management) has been updated to reflect these changes, and SECO has published the amended list on its website.
- The updated measures, including asset-freeze and prohibition obligations, enter into force on 16 June 2026 at 23:00, making the revised Syria list immediately enforceable for Swiss-supervised financial intermediaries from that time.
- Financial intermediaries are explicitly required to implement the applicable prohibitions, including restrictions on making funds or economic resources available to listed persons, entities, and organisations.
- Financial intermediaries must freeze the assets and economic resources of the persons, companies, and organisations newly listed, relisted, or otherwise affected by the Annex 7 amendment.
- Financial intermediaries must report affected business relationships and frozen assets to SECO, in line with the reporting provisions of the Syria sanctions ordinance.
Suggested Considerations
- Perform an immediate update of sanctions screening lists and tools to incorporate the revised Syria Annex 7 entries as reflected in the SESAM database.
- Identify all customers, beneficial owners, counterparties, and transactions that match or potentially match the updated Syria sanctions list, including retrospective screening where systems permit.
- Freeze without delay all assets and economic resources held or controlled by persons, entities, or organisations that are newly listed or affected by changes under the updated Annex 7.
- Block any new or pending transactions that would make funds or economic resources available, directly or indirectly, to persons and entities designated under the updated Syria list.
- Report all affected business relationships and frozen assets to SECO in accordance with the reporting requirements of the Syria sanctions ordinance and SECO guidance.
- Conduct enhanced due diligence and additional clarifications under Article 6 AMLA where there are indications or suspicions related to money laundering, terrorism financing, or criminal origin of assets connected to listed Syrian-related parties.
Key Dates
Compliance Impact
Non-compliance exposes firms to FINMA enforcement measures, including coercive administrative actions, reputational damage, and potentially severe regulatory sanctions for failures in sanctions implementation and AML controls. Breaches of Swiss sanctions and AML obligations can also create criminal liability risks for institutions and responsible individuals, particularly where prohibited economic
Who is Affected
References
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Summary
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs 7 der Verordnung vom 8. Juni 2012 über Massnahmen gegenüber Syrien (SR 946.231.172.7) publiziert.